Federal Government

Petitioner Bentley, a noncompetent ward of the Federal Government and a tribal Indian, raised cattle on tribal lands by authority of a permit issued by the tribe. He had acquired the cattle with a loan obtained pursuant to a \rehabilitation\ program operated by the tribe for its members through a grant by the Federal Government. Petitioner disposed of the cattle in 1958 and contended that the income derived therefrom was exempt from Federal income taxation. Held, the absence of any provision in a treaty or Act of Congress exempting from taxation income so derived results in its taxation. Squire v. Capoeman, 351 U.S. 1 (1956), distinguished.